GUTIERREZ, RANDY RAY v. the State of Texas

CourtCourt of Criminal Appeals of Texas
DecidedApril 16, 2025
DocketPD-0480-24
StatusPublished

This text of GUTIERREZ, RANDY RAY v. the State of Texas (GUTIERREZ, RANDY RAY v. the State of Texas) is published on Counsel Stack Legal Research, covering Court of Criminal Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
GUTIERREZ, RANDY RAY v. the State of Texas, (Tex. 2025).

Opinion

IN THE COURT OF CRIMINAL APPEALS OF TEXAS

NO. PD-0480-24

RANDY RAY GUTIERREZ, Appellant

v.

THE STATE OF TEXAS

ON STATE’S PETITION FOR DISCRETIONARY REVIEW FROM THE THIRTEENTH COURT OF APPEALS BEE COUNTY

FINLEY, J., delivered the opinion of the Court, in which SCHENCK, P.J., RICHARDSON, KEEL, WALKER, and PARKER, JJ., joined, and in which YEARY, J., joined except for Part II. NEWELL and MCCLURE, JJ., concurred.

OPINION

The difference between “Let’s eat grandma” and “Let’s eat, grandma”

illustrates two simple truths: (1) proper grammar matters, and (2) punctuation

saves lives. This case is the perfect illustration. Do poor grammar and usage GUTIERREZ – 2

errors in an indictment require reforming the judgment to a lesser-included

offense? In this case, no. Even though Appellant’s indictment unquestionably

contained grammatical mistakes, it sufficiently tracked the required language

in the aggravated sexual assault of a child statute under Section

22.021(a)(2)(B) of the Penal Code. Consequently, we reverse the judgment of

the court of appeals and remand for proceedings consistent with this opinion.

I. Background

Appellant was charged with and convicted of two counts of super

aggravated sexual assault of a child, a first-degree felony that carries a

minimum sentence of twenty-five years’ imprisonment. See TEX. PENAL CODE

§ 22.021(f)(2). On appeal, Appellant challenged the sufficiency of the evidence.

The court of appeals reversed. Gutierrez v. State, No. 13-22-00248-CR,

2024 WL 973126, at *10 (Tex. App.—Corpus Christi–Edinburg Mar. 7, 2024)

(mem. op., not designated for publication). Instead of addressing the merits of

Appellant’s sufficiency claim, the court of appeals held that the grammatical

errors in the aggravating elements section of Appellant’s indictment rendered

the indictment “indeterminate as to which aggravating element [was] being

alleged.” Id. at *7. But the indictment did charge a facially complete offense of

aggravated sexual assault of a child offense in both counts. Id. at *9.

Accordingly, the court of appeals modified the judgment on each count to reflect GUTIERREZ – 3

convictions for the lesser-included offenses, found the evidence sufficient to

sustain those convictions, and remanded the cases for a new punishment

hearing. See id. at *9–10. We granted the State’s Petition for Discretionary

Review 1 and ordered the parties to brief an additional ground for review on our

own motion. 2

II. Subsection (f): Element or Punishment Enhancement?

We first address the Court’s threshold issue: whether Subsection (f) in

Section 22.021 of the Penal Code is an element of the offense or a punishment

enhancement. The parties agree that Subsection (f) is an element of the offense

of super aggravated sexual assault of a child. We also agree.

Section 22.021(f) of the Texas Penal Code provides:

(f) The minimum term of imprisonment for an offense under this section is increased to 25 years if:

(1) the victim of the offense is younger than six years of age at the time the offense is committed; or

1 The State’s Petition for Discretionary presented the following questions:

(1) If an indictment’s grammar and usage errors produce awkward phrasing, does Delarosa v. State, 677 S.W.3d 668 (Tex. Crim. App. 2023), direct that it has failed to make an allegation?

(2) Can an indictment that sets out all of the statutory language for an enhancement in the body be said to be “facially complete” for the unenhanced offense—i.e., that it appears to allege the unenhanced offense and only the unenhanced offense? 2 The Court granted review on the following question: “Is Subsection (f) in Section 22.021 of the Penal Code an element of the offense or a punishment enhancement?” GUTIERREZ – 4

(2) the victim of the offense is younger than 14 years of age at the time the offense is committed and the actor commits the offense in a manner described by Subsection (a)(2)(A).

TEX. PENAL CODE § 22.021(f).

In Oliva v. State, 548 S.W.3d 518 (Tex. Crim. App. 2018), this Court

examined whether, under Section 49.09 of the Penal Code, entitled “Enhanced

Offenses and Penalties” for DWI offenses, subsection (a)—the offense elevation

for DWI offenses after a single prior DWI conviction—served as an element of

an offense or a punishment issue. Id. at passim. In doing so, we examined a

number of textual factors that are relevant to such a determination. First, we

looked to whether the statute “explicitly” designated a portion of it as an

element or punishment issue. Id. at 522 (citing TEX. PENAL CODE § 12.49 (“If

the court makes an affirmative finding . . . in the punishment phase of the

trial”)). Second, we considered whether the statute contained the phrase, “A

person commits an offense if,” which is the most “obvious and common method

of prescribing elements of an offense.” Id. at 523 (quoting Wilson v. State, 772

S.W.2d 118, 121–22 (Tex. Crim. App. 1989)). Third, we examined whether the

statute provided that an offense “is” of a particular grade, which denotes an

element, or instead provides for punishment by a higher degree if something

is proven, which denotes a punishment issue. Id. at 524 (citing Calton v. State,

176 S.W.3d 231, 233–34 (Tex. Crim. App. 2005)). Fourth, we looked at whether GUTIERREZ – 5

the provision included the phrase, “if it is shown on the trial of,” which is

“strongly associated with punishment enhancements.” Id. at 527 (quoting

Wilson, 772 S.W.2d at 123). Fifth, and finally, we examined whether the

provision is jurisdictional, specifically, if a finding on the at-issue portion of the

indictment would raise the offense from a misdemeanor to a felony. Id. at 528–

29. Using these factors, we concluded that the DWI 2nd enhancement was a

punishment issue. Id. at 534.

We have used the Oliva factors several times since. For example, in State

v. Green, 682 S.W.3d 253 (Tex. Crim. App. 2024), we used the factors when

examining the proper construction of the forgery statute in Section 32.21 of the

Penal Code. See id. at 256, 270. We concluded that the value ladder in Section

32.21(e-1) “constitute[d] an element of a distinct forgery-to-obtain-property-or-

services offense that may result in either an aggravated or reduced offense

level as compared to the Class A misdemeanor default.” Id. at 275. In Holoman

v. State, 620 S.W.3d 141 (Tex. Crim. App. 2021), we used the Oliva factors to

determine whether enhancements for prior conviction or impeding-circulation

enhancements for family violence assault offenses were elements of third-

degree felonies or punishment issues to raise the range of punishment after

conviction for simple assault. Id. at 143. We emphasized the fifth Oliva factor—

the jurisdictional factor—and concluded that the enhancements “operate as GUTIERREZ – 6

alternative ways to raise a simple assault-on-a-family-member to the status of

a third-degree felony. Alleging either one will suffice to invoke the district

court’s felony jurisdiction.” Id. at 145. Thus, both enhancements were elements

rather than punishment issues. Id. at 147.

But the five Oliva factors are not dispositive here. Subsection (f) is not

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Jackson v. Virginia
443 U.S. 307 (Supreme Court, 1979)
Apprendi v. New Jersey
530 U.S. 466 (Supreme Court, 2000)
Alleyne v. United States
133 S. Ct. 2151 (Supreme Court, 2013)
Curry v. State
30 S.W.3d 394 (Court of Criminal Appeals of Texas, 2000)
State v. Moff
154 S.W.3d 599 (Court of Criminal Appeals of Texas, 2004)
Calton v. State
176 S.W.3d 231 (Court of Criminal Appeals of Texas, 2005)
Saathoff v. State
891 S.W.2d 264 (Court of Criminal Appeals of Texas, 1994)
Malik v. State
953 S.W.2d 234 (Court of Criminal Appeals of Texas, 1997)
Labelle v. State
720 S.W.2d 101 (Court of Criminal Appeals of Texas, 1986)
Wilson v. State
772 S.W.2d 118 (Court of Criminal Appeals of Texas, 1989)
Daniels v. State
754 S.W.2d 214 (Court of Criminal Appeals of Texas, 1988)
Murray, Chad William
457 S.W.3d 446 (Court of Criminal Appeals of Texas, 2015)
Oliva v. State
548 S.W.3d 518 (Court of Criminal Appeals of Texas, 2018)

Cite This Page — Counsel Stack

Bluebook (online)
GUTIERREZ, RANDY RAY v. the State of Texas, Counsel Stack Legal Research, https://law.counselstack.com/opinion/gutierrez-randy-ray-v-the-state-of-texas-texcrimapp-2025.